All four active federal district judges in the U.S. District Court for the Middle District of Tennessee have recused themselves from U.S. Senator Marsha Blackburn's lawsuit against former Special Counsel Jack Smith, sending the case to the U.S. Court of Appeals for the Sixth Circuit to designate an outside judge. [1, 2]
## Key Details of the Case and Recusal
* The Lawsuit: Filed on September 30, 2026, by Senator Marsha Blackburn (R-Tenn.) against former Special Counsel Jack Smith, the 46-page complaint alleges that Smith’s "Arctic Frost" investigation illegally subpoenaed her legislative cell phone toll and metadata records. [1, 3, 4]
* Core Claims: Blackburn claims the subpoena violated the Constitution’s Speech or Debate Clause, the First and Fourth Amendments, and federal civil rights laws, while also challenging the legality of Smith’s appointment. [1, 3]
* The Recusals: Chief U.S. District Judge William L. Campbell Jr. and the remaining active judges in the Middle District of Tennessee stepped aside, with individual and full-bench recusal orders entered in early October 2026. No specific conflicts or reasons were detailed in the order. [2, 3, 5]
* Next Steps: The [Tennessee Bar Association](https://www.tba.org/?pg=Articles&blAction=showEntry&blogEntry=152764) reported that the U.S. Court of Appeals for the Sixth Circuit will now assign a judge from outside the Middle District of Tennessee to handle the proceedings. [2]
[1] [https://www.newsweek.com](https://www.newsweek.com/every-active-federal-judge-in-nashville-recuses-from-jack-smith-case-12530381)
[3] [https://www.yahoo.com](https://www.yahoo.com/news/politics/articles/4-federal-judges-recuse-sen-192009334.html)
[5] [https://www.wbir.com](https://www.wbir.com/article/news/politics/national-politics/all-federal-judges-middle-tennessee-recuse-themselves-marsha-blackburns-lawsuit-against-jan-6-special-counsel/51-5dc9f18d-cb5b-4471-8bbb-58bdd59bc52c)
